78 FR 57686 — Guidance Regarding Deduction and Capitalization of Expenditures Related to Tangible Property IRCFinal Rules (FR)Sep 19, 2013
…le property from use in the trade or business or in the production of income, see § 1.167(a)-8, § 1.168(i)-1, § 1.168(i)-1T, § 1.168(i)-8T, Prop. Reg. § 1.168(i)-1 (September 19, 2013), or Prop. Reg. § 1.168(i)-8 (September 19, 2013), as applicable. For provisions respecting the obsolescence of depreciable property for…
IRCCourt RulingsJan 17, 2024related by meaning
3 in
p articular s erve what is principally a regulatory functio n —persuading
public charities, private foundations, employee trusts, and other tax - fa vored plan s to comply with the requirement s Congress has ordaine d
for continued tax-exempt status.
Section 4973 imposes a 6% exaction on the amount of an excess
co…
IRCCourt RulingsMay 19, 2011
…cordingly, Weekend Warrior may not deduct expenses relating to
the boat.
C. Deduction Under Section 168(k) for 2002
For 2002 Weekend Warrior claimed a special depreciation
deduction of $160,000 under section 168(k) with respect to the
airplane. Respondent contends that Weekend Warrior was not
eligible for a special dep…
IRCCourt RulingsJun 29, 2010
…tabl e
to the 2004 Ford Mustang : Respondent contends that petitioners are not-entitled-t o
section 168(k bonus depreciation deduction-because the Mustang
fails to meet the definition of qualified property under section,
168 (k) . Furthermore, respondent .,argues that the Mustang -is .-
-predominantly used in a qualifi…
IRCCourt RulingsFeb 9, 2023related by meaning
services is $100,000. Assume that
the district director proposes to increase D’s income by
$100,000, but that the country in which F is located would have blocked payment in 196 5 for such services. If, prior
to the first occurring of the events described in subdivisions
(i), (ii), or (iii) of this subparagraph, D ele…
IRCCourt RulingsMay 23, 1979related by meaning
rden of proof on the unreasonable compensation issue since he raised it in his amended answer. Rule 142(a), Tax Court Rules of Practice and Procedure. Turning to the merits, we note that respondent argues that the case of Bianchi v. Commissioner, 66 T.C. 324 (1976), affd. per curiam 553 F.2d 93 (2d Cir. 1977), is direc…
IRCCourt RulingsAug 30, 1999related by meaning
in effect ordered him to
satisfy the increased amount awarded to Ms. Czepiel by making the
IRA distributions since the only funds available to him in January 1995 to pay that amount consisted of approximately
$33,000 on deposit in his IRA's. Respondent counters that the
divorce judgment is not a QDRO and that petition…
76 T.C. 433 — Ralph Gano Miller (Corp.) v. Commissioner IRCCourt RulingsMar 17, 1981related by meaning
es not meet the requirements of section 401(a).
Accordingly, we need not consider the State law question.
Decision nñll be entered for the respondent. This plan was entitled the “Third Amendment to the Miller & Kearney Stock Bonus Plan and Trust” which amended and restated petitioner’s original plan in its entirety.
Mo…
Notice 2011-3 — Special rules relating to funding relief for single-employer pension plans under PRA 2010. This notice provides guidance on the special rules relating to fundi… IRCNoticesJan 10, 2011
…ation adjustment:
Year Shortfall amortization installments
Before adjustment After adjustment
2012 $168,458 $382,458
2013 168,458 168,458
2014 168,458 168,458
2015 168,458 168,458
2016 168,458 168,458
2017 168,458 37,233
2018 168,458 0
Present value as of January 1, 2012 $1,000,426 $1,000,426
Q I-4: How is the § 430(c)…
IRCCourt RulingsJul 2, 2002
…371, the
amount owed him by Stephanie and David when he took the deed in
lieu of foreclosure, plus $168,957, the amount outstanding on the
note held by Great Western. Petitioner acknowledges but does not
explain the $2,997 difference between the basis he claimed on his
return, $336,331, and the sum of the two amounts h…
IRCCourt RulingsMay 30, 1984related by meaning
was that it was "clarifying” the "existing” law by rejecting respondent’s position regarding the applicability of sec. 403 to public school employees. Neither party has advanced any argument herein based upon the legislative history of sec. 403(b) and of sec. 2039(c). Nor was this legislative history considered in Esta…
IRCCourt RulingsAug 6, 1991related by meaning
f the matter is that the payment in question should be taxable to petitioner under section 72(e). Accordingly, we sustain respondent’s determination.6 In order to take into account what appear to be mechanical errors in respondent’s calculations and to afford the parties a further opportunity to resolve the question of…
T.C. Memo. 1999-80 — Edward Clasby and C. T. Garrahan Insurance Agency, Inc. v. Commissioner IRCCourt RulingsMar 16, 1999related by meaning
ions to tax under section
6651(a)(2) and that the addition to tax under section 6651(a)(1)
for 1993 is not larger than $7,959. We sustain respondent's determination that petitioners are liable for additions to tax
under section 6651(a)(1), except as conceded by respondent.
Decision will be entered
under Rule 155
.
IRCCourt RulingsSep 13, 1990related by meaning
y [section 403(a) of ERTA],
then the amendment made by [section 403(a) of ERTA] shall not apply to the estate of such decedent.
[1981-2 C.B. 326-327.] *295 Respondent asserts that all the conditions contained in section 403(e)(3) have been met. Therefore, *99 he maintains, petitioner is not entitled to an unlimited mar…
IRCCourt RulingsJul 5, 1983related by meaning
so determined that petitioners were liable for an addition to tax under sec. 6651(a) in the amount of $28.76. Respondent conceded that issue on brief. The procedures set forth in sec. 7463 apply to cases involving taxes imposed by subtitle A and Chs. 11 and 12 of the Code, subject to monetary limits. As to petitions fi…
T.D. 9275 — Final regulations under section 410 of the Code implement a statutory directive of the Economic Growth and Tax Relief Reconciliation Act of 2001 (EGTRRA) to am… IRCTreasury DecisionsAug 28, 2006related by meaning
n the information elicited on those line items, as well as the rest of the form, in their books and records.
Announcement 2006-56 Announcement 2006-56 This document contains corrections to temporary regulations (T.D. 9262, 2006-24 I.R.B. 1040) concerning the application of section 199 of the Code, which provides a dedu…
Notice 2009-57 — Weighted average interest rate update; corporate bond indices; 30-year Treasury securities; segment rates. This notice contains updates for the corporate bond … IRCNoticesJul 20, 2009
INCOME TAX
Rev. Proc. 2009-33 Rev. Proc. 2009-33
Section 168(k)(4) extension property guidance. This procedure provides guidance with respect to section 168(k)(4) of the Code, which was extended by section 1201(b) of the American Recovery and Reinvestment Tax Act of 2009 (the Act) to allow corporations to elect not to …
IRCCourt RulingsJun 30, 1982related by meaning
ance standard of section 162(a)(1). Bianchi v. Comm issioner, 66 T.C. 324, 329-330 (1976), affd. without published opinion 553 F.2d 93 (2d Cir. 1977). Respondent contends that in order for a contribution to a pension plan to be deductible under section 404, the contribution must represent compensation for personal serv…
36 T.C. 491 — Hiawatha Home Builders, Inc. v. Commissioner IRCCourt RulingsJun 9, 1961related by meaning
ter refer only to section 1551, the provisions of which are as follows :
SEC. 1551. ¡DISALLOWANCE OF SURTAX EXEMPTION AND ACCUMULATED EARNINGS CREDIT. If any corporation transfers, on or after January 1, 1951, all or part of its property (other than money) to another corporation which was created for the purpose of acq…
IRCCourt RulingsMar 5, 2018related by meaning
r I.R.C. sec. 4973.
He] : On the facts presented, Ps and not their Roth IRAs were
the owners, for Federal tax purposes, of the FSC stock; in substance the FSC dividends were income to Ps, who contributed the funds to
their Roth IRAs. Summa Holdings, Inc. v. Commissioner, 848 F.3d
779 (6th Cir. 2017), rev'g T.C. Memo. 2…